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March 20, 2008

Chemical inventory completed for Homeland Security

Pitt has completed its chemical inventory list as required by the Department of Homeland Security (DHS).

Under a mandate from Homeland Security issued Nov. 20, institutions of all kinds nationally were required to inventory their holdings of more than 325 used or stored “chemicals of interest,” that is, chemicals that in sufficient quantities pose a potential security or human health threat. (See Nov. 8 University Times.)

Pitt initially faced a January deadline to comply, but was granted an extension until March 22. The University filed its information on Feb. 28 and subsequently received an acknowledgment of compliance from Homeland Security, according to Jay Frerotte, director of Environmental Health and Safety (EHS).

In the end, Frerotte said, Pitt was required to list only three chemicals that surpassed the screening threshold quantity set by Homeland Security.

“That’s not really surprising, because the list of chemicals were targeted mainly for their potential to be used as chemical weapons, and we wouldn’t have many of those,” Frerotte said this week. “What really made a difference for us — and I’m sure for most research institutions — was that DHS prudently set an appropriately high screening threshold quantity for common research chemicals. That really changed the playing field for us. On their initial list, many of the chemicals needed to be reported if we had any amount. Now some of the more common chemicals have a threshold amount of 2,000 pounds and more.”

As an example, one of the three chemicals Pitt reported is an extremely common acid found in many laboratories, especially at research institutions, he said. “The threshold quantity was 400 pounds and, collectively, because we are such a large university, we happen to be over that threshold.”

Frerotte declined to specify the chemicals Pitt had to report. “I don’t want to set a precedent of publicly announcing information of that sort,” he said.

EHS completed the inventory of Pitt’s chemical holdings by working through the departments, Frerotte said. “We sent letters to department chairs and copied the deans on Dec. 11. Along with the memorandum, we sent an eight-page form developed by EHS as a guide. We were very pleased with the response and gratified by the cooperation we got.”

For example, one researcher reported having a chemical over the threshold quantity, but was willing to destroy it, Frerotte said. “We destroyed it through our normal hazardous chemical waste program, and that was perfectly acceptable.”

In addition to developing the eight-page guide, EHS hazardous materials experts fielded a number of inquiries from researchers, calculated the sums of the chemicals against the threshold limit and completed the DHS online “consequence assessment tool,” Frerotte said, all of which took about 250 staff hours.

“What we were providing Homeland Security was a snapshot,” he noted. “Since then, we have begun discussions with Purchasing — and at this point it’s only conceptual — but we want to develop a way to monitor future chemical acquisitions. It seems clear that if we obtained any of these chemicals that put us over the threshold, we would need to report that to Homeland Security. Because we have the accumulated information, it makes sense that EHS be involved in the acquisition approval process.”

Submission of the inventory information will allow Homeland Security to make preliminary determinations about whether facilities present a high level of security risk, according to information posted on the Homeland Security web site.

Facilities determined by Homeland Security to present a concern “will have to comply with the substantive requirements of CFATS (Chemical Facility Anti-Terrorism Standards) — e.g., preparing a security vulnerability assessment, developing and implementing a site security plan, etc. While some academic institutions may have security measures in place that will help them meet the applicable risk-based performance standards, some may not, and DHS looks forward to helping those facilities increase their security,” the web site states.

Frerotte said, “What that means is that Homeland Security will evaluate our information and put us in a risk category. Then they may ask us to put security measures in place, or not. We’re in a wait-and-see mode until we hear from them.”

—Peter Hart

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